Phenomenalism
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“A final, and perhaps the most devastating objection, to phenomenalism was formulated by R. Firth (1950). The objection stems from perceptual relativity: White wallpaper looks white under white light and red under red light, etc. Any possible course of experience resulting from a possible course of action will apparently underdetermine our surroundings: It would determine, for example, that there is either white wallpaper under red light or red wallpaper under white light, and so on. On what basis are we to decide which of the hypotheses is the correct one if we are constrained to rely exclusively on sensibilia?”
That objection was by R. Chisholm in “Phenomenalism,” the appendix to his book Perceiving: A Philosophical Study. (1957) R. Firth, in “Ultimate Evidence,” in fact defends the strong empiricist thesis, which depends on phenomenalism.